Conversion Therapy Laws Around the World

Conversion therapy bans compared as of October 2026: legal definitions, gender identity, carve-outs for exploratory therapy, prosecutions and Chiles v. Salazar.

Overview

About 15 countries have national laws against "conversion therapy", several more have rules issued by a health ministry or professional regulator, and many states, provinces and cities have their own. Their declared target is the same everywhere: coercive or abusive attempts to make gay people straight, or to make trans people stop identifying as trans. They differ a great deal in who they cover, what they forbid, and, most importantly for detransitioners and questioning people, what they say about therapy that explores gender distress without assuming the answer.

This page compares those laws as of October 2026, from the statute texts where we could obtain them. It quotes the definitions and carve-outs word for word, because a clause such as "identity exploration" or "considering undergoing a gender transition" decides whether a therapist feels free to ask questions. For the broader legal picture, see sex vs gender identity in law. For the therapy model at the centre of the debate, see gender exploratory therapy. This page is not legal advice.

These laws also carry a real danger for people in gender distress. Most define conversion broadly, as any effort to "change or suppress" a gender identity, but name only affirmation and help towards transition as safe. Because no test can show who is "truly trans", and identities can change, that framing can push therapists towards affirmation-only care. See the risk to exploratory psychotherapy.

Key findings: most laws that cover gender identity expressly protect help "considering" transition, but only a few expressly protect probing, caution or reflection (Queensland, France, the Netherlands) or set a high bar before health care counts as conversion (the England and Wales draft). Prosecutions are almost non-existent: Victoria, New Zealand, Canada and Norway report none. In Chiles v. Salazar (2026) the US Supreme Court held that a ban which allows affirming talk therapy but forbids questioning it discriminates by viewpoint. The main risk for questioning people is not prosecution but the pressure these definitions put on therapists to affirm rather than explore (see below).

Key terms

  • Conversion therapy / conversion practices: efforts to change or suppress a person's sexual orientation or gender identity. Laws increasingly say "practices" because many of the acts are not therapy.
  • Sexual orientation change efforts (SOCE): the research term for attempts to change sexual orientation, the original meaning of conversion therapy.
  • Gender identity change efforts (GICE): the equivalent term when the aim is to change a gender identity.
  • Change vs suppression: "change" laws target attempts to alter an identity. "Suppression" laws also target attempts to stop someone expressing or acting on it, which is a wider net.
  • Gender transition: social steps (name, pronouns, clothing) and/or medical steps (hormones, surgery) to live as the other sex.
  • Exploratory therapy: talk therapy that explores the causes and meaning of gender distress without a set outcome. Critics call some forms of it conversion therapy; supporters reject that.
  • Affirmation clause: a statutory exemption for therapy that is "supportive of or affirms" an identity, or assists a person "considering" transition.
  • Professional-judgement exemption: an exemption for health practitioners acting within their "reasonable professional judgement" and professional standards.
  • Detransition: stopping or reversing a gender transition. Desistance means ceasing to identify as trans without having medically transitioned.

Where the term came from

Conversion therapy first meant attempts to turn gay, lesbian and bisexual people heterosexual. Researchers now call these sexual orientation change efforts (SOCE). In the mid-20th century they included aversion therapy: pairing same-sex arousal with pain or disgust. A 2009 American Psychological Association (APA) task force listed methods such as "inducing nausea, vomiting, or paralysis; providing electric shocks" or snapping an elastic band on the wrist (APA 2009).

The same task force carried out a systematic review (a structured search and appraisal of all published studies). It concluded that efforts to change sexual orientation "are unlikely to be successful and involve some risk of harm". Early aversive studies recorded side effects including "loss of sexual feeling, depression, suicidality, and anxiety" (APA 2009). Later practice moved to talk-based "reparative therapy", prayer and religious counselling, which some participants also report as harmful. This history is real, and the people who lived through it are among the strongest supporters of bans.

Several detransitioners on /r/detrans describe surviving it themselves:

I'm someone who was subject to conversion therapy. It is not a helpful process in any means and it has led to many issues in those it has been used on, including myself and others... those of us who didn't end up taking our lives a few years later anyways. —DetransIS, detrans intersex female

How gender identity was added

From about 2015, laws and professional statements began to add gender identity (a person's inner sense of being a man, a woman, both or neither) and sometimes gender expression (outward presentation such as clothing and mannerisms) to sexual orientation. Malta's 2016 Act was the first national law in Europe to do so. In 2020 the United Nations (UN) Independent Expert on sexual orientation and gender identity defined "conversion therapy" as an umbrella term for interventions premised on the belief that a person's "sexual orientation and gender identity, including gender expression, can and should be changed or suppressed" (UN A/HRC/44/53, para. 17). The same paragraph says such practices aim at a change "from trans or gender diverse to cisgender".

This merger is where the controversy starts. Sexual orientation is not usually treated as a symptom of anything else. Gender distress, by contrast, often appears alongside trauma, autism, eating disorders, depression or same-sex attraction, and some young people come to understand it differently once those links are explored (Clarke & Spiliadis 2019). A therapist who explores those links could, critics argue, be accused of trying to "change" or "suppress" an identity.

Comparison table

"Anyone" means the ban covers non-professionals such as religious counsellors or family members. Quotes are from the statute. Where a law has no carve-out, the cell says so.

JurisdictionYearScopeGender identity?Exploratory / neutral therapy carve-outMax. penaltySource
Brazil (psychology regulator)1999; 2018Psychologists; all agesYes (2018)None; bans conversion "from a pathologising perspective"Professional disciplineCFP
Ontario, Canada2015Health providers; under 18Yes"identity exploration or development"Professional disciplineBill 77
Malta2016Professionals: anyone; others: vulnerable peopleYes, and expression"exploration and, or free development of a person"; treatment of "a mental disorder"1 year; €10,000Cap. 567
Germany2020Anyone; under 18, or adults with flawed consentYesNone in statute; memorandum says therapy conversations "generally" not covered1 yearKonvBehSchG
ACT, Australia2020Anyone; children and impaired adultsYes"identity exploration and development"; "considering undergoing a gender transition"12 monthsA2020-49
Queensland, Australia2020Health providers only; all agesYes"exploring psychosocial factors with a person or probing a person's experience of ... gender identity"18 monthss. 213F
Quebec, Canada2020Anyone; all agesYes, and expressionSupport for a "self-initiated process of accepting, adapting to and affirming"; no exploration clauseFine $50,000S.Q. 2020, c. 28
Victoria, Australia2021 (in force 2022)Anyone; all ages; consent irrelevantYes"supportive of or affirms"; "considering undergoing a gender transition"; "identity exploration and development"10 yearsAct 3/2021
Canada (federal)2021 (in force 2022)Anyone; all agesYes, and expression"exploration or development of an integrated personal identity" if "not based on an assumption" one identity is preferable5 yearss. 320.101
France2022Anyone; all agesYesStatements that "merely urge caution and reflection" to a young person considering medical transition3 yearsPenal Code art. 225-4-13
New Zealand2022Anyone; under-18s, or serious harm at any ageYes, and expressionPractitioner's "reasonable professional judgement"; "considering undergoing, a gender transition"; "identity exploration"5 years2022 No 1
Greece2022Minors and adults under guardianshipYes, and expressionNone; consenting adults permittedPrison and fine (unspecified)Law 4931/2022
Spain2023Anyone; all ages; consent irrelevantYes, and expressionNoneFine €150,000 (administrative)Law 4/2023
Cyprus2023Anyone; all agesYes, and expressionServices "concerning exploration and/or free development", if they do not seek change3 yearsLaw 39(I)/2023
Iceland2023Anyone using coercion, deception or threats; childrenYes, and expressionNone; limited to "non-evidence-based treatment"4 yearsart. 227b
Belgium2023Anyone; all agesYes, and expressionHealthcare help "relating to the exploration and development" of identity2 yearsLaw of 31 July 2023
Norway2024Anyone; all agesYesNone in statute6 years (aggravated)ss. 270-270b
Portugal2024Anyone; all agesYes, and expressionOnly procedures under the self-determination law; psychotherapy named as a possible method5 yearsLaw 15/2024
Mexico2024Anyone; all agesYes, and expressionNone6 years (doubled for minors)DOF 7 June 2024
NSW, Australia2024 (in force 2025)Anyone; all agesYes"genuinely assisting an individual who is exploring"; "genuinely advising ... about the potential impacts of gender affirming medical treatment"5 yearsAct No 19
South Australia2024 (in force 2025)Anyone; all agesYesAs NSW5 yearsAct No 39
Netherlands (not yet in force)2026Professionals and organisations; minors, or adults where dominance is abusedYes (not expression)Urging "restraint, caution or reflection with regard to a social or medical transition"2 years (habitual)Stb. 2026, 294
Colorado, US (example)2019Licensed providers; under 18Yes"identity exploration and development" if it "does not seek to change"; talk therapy limited by ChilesProfessional disciplineC.R.S. § 12-245-202
England and Wales (draft)2026 draftAnyone; all ages; abusive practices causing serious harmYes ("transgender identity")Health care excluded unless it falls "far below the standards reasonably expected"5 yearsCP 1604

Diagnosis-only rules in Argentina (2010), Uruguay (2017) and Chile (2021), and ministry or regulator guidance in Taiwan, Israel, India and Vietnam, are covered in the regional sections below.

Timeline

  • 1999: Brazil's psychology council bars psychologists from treating homosexuality as a disorder.
  • 2009: An APA task force finds sexual orientation change efforts "unlikely to be successful".
  • 2010: Argentina's mental-health law forbids diagnosis based solely on sexual identity.
  • 2012: California becomes the first US state to ban conversion therapy for minors by licensed providers (as widely reported; not reviewed for this page).
  • 2015: Ontario passes its law; the UK Memorandum of Understanding (MoU) is first signed; Ferguson v. JONAH fraud verdict in New Jersey.
  • 2016: Malta passes the first national ban in Europe, covering gender identity.
  • 2017: The UK MoU adds gender identity.
  • 2018: Brazil extends its rule to trans people; Taiwan's health ministry letter.
  • 2020: Germany, the ACT, Queensland and Quebec pass laws; the UN Independent Expert's report calls for a global ban.
  • 2021: Victoria's Act (in force February 2022); Canada's Bill C-4 (in force 7 January 2022); Madras High Court ruling in India.
  • 2022: France, New Zealand and Greece; Israel's health ministry directive; Vietnam's ministry letter.
  • 2023: Spain, Cyprus, Iceland and Belgium; Norway passes its law (in force 1 January 2024).
  • 2024: Portugal (January), Mexico (June), NSW (passed) and South Australia (October); UKCP leaves the MoU; the Cass Review warns against equating exploration with conversion.
  • 2025: NSW and South Australia laws in force (April); the HHS review criticises the "conversion therapy" label; Scotland pauses its bill.
  • 31 March 2026: Chiles v. Salazar.
  • 13 May 2026: the European Commission declines to propose an EU-wide ban.
  • 25 June 2026: draft Conversion Practices Bill for England and Wales published.
  • 30 September 2026: the Dutch Act is published, not yet in force.

The risk to exploratory psychotherapy

The laws on this page were written to stop abuse. But the way many of them define their target creates a separate danger, for people with gender distress and for the clinicians who treat them. They define the offence broadly, as any effort to "change" or "suppress" a gender identity. Then they name only one direction of help as safe: affirming the identity, or helping a person move towards transition. A therapist who asks whether the distress has other causes is not named as safe. In practice this can push clinicians towards affirmation-only care (accepting a stated identity without exploring it), which carries its own risks of harm.

One direction protected, the other exposed

The asymmetry is in the statutory wording itself:

  • Victoria targets any practice for the purpose of "changing or suppressing" a gender identity, "whether with or without the person's consent", and names "providing a psychiatry or psychotherapy consultation" as one possible form. Its exclusions cover practice that is "supportive of or affirms a person's gender identity", including "assisting a person who is considering undergoing a gender transition".
  • New Zealand forbids acts done "with the intention of changing or suppressing" a gender identity, and excludes "assisting an individual who is undergoing, or considering undergoing, a gender transition".
  • Canada targets efforts to change a gender identity "to cisgender" or to "repress a person's non-cisgender gender identity". Only one direction of change is named.
  • Colorado excluded "Assistance to a person undergoing gender transition". Germany says hormones or surgery expressing a person's "self-perceived gender identity" are not conversion treatment.
  • Mexico reaches any practice that "obstructs, restricts, impedes, impairs, nullifies or suppresses" an identity, and Portugal names "psychotherapeutic" acts. Neither has an exploration clause.

None of these texts protects, in the same plain words, helping a person who decides not to transition, or a therapist who suggests that distress may be better explained by something else. Most laws do protect "identity exploration", and some protect "reasonable professional judgement" (see Key terms). But those are open-ended phrases. The affirming direction is named and safe. The exploring direction is protected only if a regulator or court later agrees that the therapist was exploring rather than suppressing. A cautious clinician can avoid that question entirely by affirming.

Why exploration matters clinically

Gender distress often comes with other difficulties, such as trauma, autism, depression or self-harm. Two clinicians at the former UK Gender Identity Development Service (GIDS) described 12 teenagers who asked for hormones or blockers and then stopped wanting them during a longer assessment. Seven of the 12 had an autism diagnosis and seven had self-harmed; seven came to feel comfortable with their sex (Clarke & Spiliadis 2019). It is a small case series picked by outcome, but it shows what exploration can find. Exploring these links is not an attempt to change who someone is. It is ordinary psychotherapy: finding out what is causing the suffering before choosing a treatment.

The two biggest government-commissioned reviews of youth gender care both warned against treating that work as conversion:

  • The Cass Review (England, 2024) said terms such as "affirmative" and "exploratory" had been "weaponised" (para. 11.4). It said the intent of therapy is "to explore their concerns and experiences and help alleviate their distress", and that "It is harmful to equate this approach to conversion therapy" because it "may prevent young people from getting the emotional support they deserve" (para. 11.6). It added that "No formal science-based training in psychotherapy, psychology or psychiatry teaches or advocates conversion therapy" (para. 11.7) (Cass 2024).
  • The HHS review (United States, 2025) said there is "a dearth of research on psychotherapeutic approaches", "due in part to the mischaracterization of such approaches as 'conversion therapy'". It called the use of that label for "any approach focused on reducing a minor's distress about their body or social role" a "problematic and potentially harmful rhetorical device" (HHS 2025).

There is evidence that clinicians have pulled back. In the 2025 Australian family court case Re Devin, experts said "a lack of clarity about how the Act applies to health professionals may discourage them from treating children with gender issues". The judge said this "may explain some of the difficulties" in finding expert witnesses (VLRC 2026). Therapy First, a group of exploratory clinicians that supports US bans as written, says "misinterpretation and misuse of these laws has led to a chilling effect" (Therapy First FAQ, advocacy). A commenter on /r/detrans who works in mental health described the same pattern:

I work in the mental health industry and I can tell you that there are plenty of therapists who either affirm-only or refer out for trans clients; the risk of lawsuits and revoked licenses is too high. —keycoinandcandle, desisted male

No test for who is "truly trans"

There is no blood test, brain scan or other biomarker that shows whether a person's gender identity is innate, lasting or the best explanation for their distress. Brain-sex research does not provide one (see what the science actually shows). A widely cited 2022 brain-scan study claiming that trans women's brains are shifted towards women's has been criticised for weak statistics and for ignoring sexual orientation (Wright et al. 2026). The idea of a "true trans" core group has no agreed diagnostic criteria. The only evidence of an identity is what the person reports, and what they report can change.

It does change, for some people. In a follow-up of 139 boys seen at a Toronto clinic for gender distress, 87.8% no longer had it by about age 21 (Singh et al. 2021). That clinic worked in an earlier era, and much of its therapy then aimed to reduce cross-gender behaviour, so the figure cannot simply be applied to young people today. But it shows that childhood gender distress often does not last. Adolescents and adults also desist, detransition, or find that their identity changed over time.

This is the core problem. A law that treats any effort to "change" a gender identity as harm presumes that the identity is already fixed and known. Finding that out is exactly what clinical exploration is meant to do. If identity can shift, and nobody can test for it, then a therapist who explores is not overriding a settled fact about the client. They are asking an open question that the law has already answered.

The harm of affirmation-only care

Affirmation is not risk-free. When questions are avoided, the next step is often medical: hormones, then sometimes surgery, with effects that may not be reversible (see iatrogenic harm). Many detransitioners on /r/detrans describe therapy that confirmed their self-diagnosis without examining what else was going on:

My entire transition was a result of mental illness. And it was affirmed without question. It was so insanely easy for me to receive care purely on the basis of my own belief that it was necessary. No one bothered to take a good look at my pre-existing issues and wonder how they might come into play. —mothmourning, detrans female

If I had received actual treatment instead of affirmation, I probably would have been diagnosed with what I now know, as an adult, are my disorder of sex development, my PTSD and my anorexia, and I would been able to have those things treated competently and conservatively. Instead, I'm sterile now. —Icy_Owl7841, detrans

These accounts are self-selected, and they do not show how common such experiences are. They do show what is at stake when a therapist feels safer not asking. For the alternative model, see gender exploratory therapy.

The other side, and why the chilling effect persists

Lawmakers say they are not targeting therapy. The England and Wales draft says it is not "seeking to ban explorative conversations and questioning about someone's identity", and most laws exempt "identity exploration" or professional judgement. The abuses these laws were written against were real: aversion therapy, coercion and religious "cures" that survivors describe as torture (see where the term came from and trans perspectives). And prosecutions are almost non-existent (see what actually happens).

Critics reply that a chilling effect does not need prosecutions. Clinicians are cautious by training. A complaint to a regulator, an employer's policy, an insurer's rule or a professional body's guidance can carry career risk long before any court is involved. When the law names affirmation as safe and leaves exploration to interpretation, the cheapest way for a therapist to stay safe is to affirm. The few laws that expressly protect "caution and reflection" (France), "restraint, caution or reflection" (the Netherlands) or "probing" an experience of gender identity (Queensland) show that this risk can be drafted away. Most laws have not done so.

Regional detail

Canada

Federal Criminal Code (2022). Bill C-4 (S.C. 2021, c. 24) came into force on 7 January 2022 (Library of Congress). It applies to people of all ages and to anyone, not just licensed professionals. Section 320.101 defines conversion therapy as "a practice, treatment or service designed to" change a person's sexual orientation "to heterosexual", change their gender identity "to cisgender", or "repress a person's non-cisgender gender identity", among other limbs. Its carve-out reads in full:

For greater certainty, this definition does not include a practice, treatment or service that relates to the exploration or development of an integrated personal identity — such as a practice, treatment or service that relates to a person's gender transition — and that is not based on an assumption that a particular sexual orientation, gender identity or gender expression is to be preferred over another. — (Criminal Code, s. 320.101)

Causing someone to undergo conversion therapy carries up to five years' imprisonment on indictment (s. 320.102). Separate offences cover promoting or advertising it and profiting from it.

The wording matters. Exploration is protected only if it is "not based on an assumption" that one identity is preferable. Critics ask whether a therapist who thinks a teenager's distress is better understood as trauma, rather than as a fixed identity, is making such an assumption. Supporters reply that neutral exploration, by definition, is not. No court has ruled on the point. In January 2023 the federal Justice department said it knew of no charges (Global News), and we found none since (not confirmed).

Provinces. Ontario (2015) bars health providers from treatment that "seeks to change the sexual orientation or gender identity" of an under-18, excluding "services that provide acceptance, support or understanding of a person or the facilitation of a person's coping, social support or identity exploration or development" (Ontario Bill 77). Nova Scotia (2018) uses the same exploration wording for under-19s (S.N.S. 2018, c. 28, s. 8). Quebec (2020) applies to anyone and all ages, with fines up to $50,000 for individuals. It excludes support "in their self-initiated process of accepting, adapting to and affirming" an identity. It does not mention exploration (S.Q. 2020, c. 28).

United States

State laws. There is no federal ban. According to the Movement Advancement Project (MAP, an LGBT advocacy group), as of October 2026, 22 states and the District of Columbia ban licensed providers from practising conversion therapy on minors, five more states and Puerto Rico have partial bans, and 106 localities have ordinances (MAP, advocacy). Almost all cover gender identity. They regulate only licensed professionals, and only with clients under 18.

Colorado's law is typical. It defines conversion therapy as any practice that "attempts or purports to change an individual's sexual orientation or gender identity, including efforts to change behaviors or gender expressions". It excludes "Acceptance, support, and understanding for the facilitation of an individual's coping, social support, and identity exploration and development ... as long as the counseling does not seek to change sexual orientation or gender identity" and "Assistance to a person undergoing gender transition" (C.R.S. § 12-245-202(3.5)).

Chiles v. Salazar (2026). Kaley Chiles, a licensed Christian counsellor, challenged Colorado's law. She said she offered only talk therapy to clients who themselves wanted to reduce same-sex attraction or feel comfortable in their bodies. On 31 March 2026 the Supreme Court ruled 8-1 in her favour (Chiles v. Salazar, No. 24-539). The holding:

Colorado's law banning conversion therapy, as applied to Ms. Chiles's talk therapy, regulates speech based on viewpoint, and the lower courts erred by failing to apply sufficiently rigorous First Amendment scrutiny. — (Chiles v. Salazar 2026)

Justice Gorsuch wrote that "Her speech does not become conduct just because the State may call it that", while noting that the law "may address conduct—such as aversive physical interventions" in other applications. Justice Kagan, joined by Justice Sotomayor, concurred and said a "content-based but viewpoint-neutral law" would "raise a different and more difficult question". Justice Jackson dissented, arguing that states have long regulated medical practice.

The core of the ruling is the asymmetry. A law that lets therapists affirm a gender identity but forbids them to question it picks a side in a debate, and the First Amendment requires the state to justify that under strict scrutiny (the hardest test in US constitutional law). The case was sent back. The Tenth Circuit remanded it in May 2026, and the federal district court in Colorado granted Chiles a preliminary injunction in June 2026 (Colorado Springs Gazette, 9 June 2026, as reported; the order was not reviewed). Colorado passed HB26-1322 in June 2026 to redefine the ban around a "predetermined outcome" (press reports; text not reviewed). In Michigan, a stipulated judgment in Catholic Charities v. Whitmer in July 2026 reportedly declared that state's ban unconstitutional as applied to talk-only therapy (not confirmed). We found no state that has repealed its ban outright. For other US developments, see the United States.

Federal government. The 2025 HHS review (the US Department of Health and Human Services' evidence review of youth gender medicine) argued that "There is a dearth of research on psychotherapeutic approaches", "due in part to the mischaracterization of such approaches as 'conversion therapy'" (HHS 2025). Its authorship and independence are disputed.

United Kingdom

The long-promised ban. The 2018 LGBT Action Plan promised to end conversion therapy in England and Wales. A 2021-22 consultation drew 28,569 valid responses, but its analysis was published only in June 2026 (GOV.UK). In 2022 the government said trans conversion would be handled through "separate work"; in January 2023 it promised a trans-inclusive draft bill that was never published (Written statement, 17 Jan 2023).

The 2026 draft bill. On 25 June 2026 the government published a draft Conversion Practices Bill (CP 1604) for England and Wales (GOV.UK). It defines a conversion practice as conduct intended to cause someone "to have or not to have" a sexual orientation or "a transgender identity". Its health-care clause, cl. 1(3), reads: conduct "carried out in the course of providing health care services to the individual concerned, is not a conversion practice unless the person acts in a way that falls far below the standards reasonably expected of a person in their position". The explanatory notes call this "equivalent to a threshold of gross negligence".

The offence (cl. 2) applies only to an abusive conversion practice that causes "serious harm" to physical or mental health, or serious alarm or distress with "a substantial adverse effect" on daily life. Abuse factors include coercive control, threats and "psychological or emotional pressure". The maximum penalty is five years. The government said it was not "seeking to ban explorative conversations and questioning about someone's identity" (GOV.UK press release). Hilary Cass, who led the NHS review of youth gender services, welcomed "a clearer definition of what conversion practices are, compared to previous drafts, but also what they are not". The bill has no express clause on parents or religious conversations.

Status as of October 2026: draft only, not law. A joint committee of both Houses is being appointed for pre-legislative scrutiny and aims to report by 22 January 2027 (Commons debate, 9 Sept 2026). See also the United Kingdom.

Scotland, Wales and Northern Ireland. Scotland consulted in 2024 but in May 2025 decided "not to introduce legislation to the Scottish Parliament this session". In September 2026 its minister said it would seek to extend the UK bill to Scotland and "should the UK Government fail to deliver we will introduce our own Bill" (Scottish Parliament letter, 4 Sept 2026). Wales is covered by the UK draft. In Northern Ireland a private member's Conversion Practices (Criminalisation) Bill was introduced on 30 June 2026 and reached Committee Stage in late September (NI Assembly).

The Memorandum of Understanding

Separately from the law, the main UK therapy and health bodies signed a Memorandum of Understanding on Conversion Therapy (MoU), a voluntary professional pledge first issued in 2015. Version 2 (2017) added gender identity. It defines conversion therapy as an approach that "demonstrates an assumption that any sexual orientation or gender identity is inherently preferable to any other". The July 2024 revision adds that it is "not intended to deny, discourage or exclude those with uncertain feelings around sexuality or gender identity from seeking qualified and appropriate help", nor to stop clinicians "performing a clinical assessment of suitability prior to medical intervention" (MoU, July 2024).

The UK Council for Psychotherapy (UKCP), a major registering body, withdrew from the MoU on 5 April 2024. It said "The current MoU was drafted to apply to adults" and drew "No safeguarding distinctions between adults and children and young people", while still opposing conversion therapy "for any age" (UKCP). In November 2023 it had already issued guidance "that exploratory therapy must not be conflated with conversion therapy" (UKCP 2023).

Australia

Australia has no national law, but five of its eight states and territories do, as of October 2026.

  • Australian Capital Territory (ACT), 2020. The Sexuality and Gender Identity Conversion Practices Act 2020 bans practices whose purpose is "to change a person's sexuality or gender identity" when performed on a child or a person with impaired decision-making ability (max. 12 months' imprisonment). Section 7(2) excludes practices to "assist a person who is considering undergoing a gender transition" and to "facilitate a person's coping skills, social support or identity exploration and development"; s. 7(3) exempts health providers acting as "necessary" to provide a safe health service (ACT Legislation).
  • Queensland, 2020. A health-service-only ban: "A person who is a health service provider must not perform conversion therapy" (Public Health Act 2005, s. 213H). It is the only Australian law whose examples of non-conversion practice expressly include "exploring psychosocial factors with a person or probing a person's experience of sexual orientation or gender identity" (s. 213F(3)). Penalties reach 18 months' imprisonment for a vulnerable person (Queensland Legislation).
  • Victoria, 2021. The broadest law: it covers all ages, anyone, and applies "whether with or without the person's consent". Section 5(1) targets conduct aimed at "changing or suppressing" orientation or gender identity, and s. 5(3) lists "providing a psychiatry or psychotherapy consultation" and "a prayer based practice" as possible forms. Section 5(2) excludes practices that are "supportive of or affirms a person's gender identity", including "assisting a person who is considering undergoing a gender transition" and "facilitating a person's coping skills, social support or identity exploration and development", plus health practice that is "in the health service provider's reasonable professional judgement, necessary". Causing serious injury carries up to 10 years (Victorian Legislation). It came into force on 17 February 2022.
  • New South Wales (NSW), 2024. The Conversion Practices Ban Act 2024 has been in force from 4 April 2025. It covers any "practice, treatment or sustained effort" directed at "changing or suppressing" orientation or gender identity. Its health exclusion requires a registered practitioner's "reasonable professional judgement", with examples such as "genuinely assisting an individual who is exploring the individual's sexual orientation or gender identity or considering or undergoing a gender transition" and "genuinely advising an individual about the potential impacts of gender affirming medical treatment". It also says parents discussing these matters with their children is not a conversion practice. Causing substantial harm carries up to five years (NSW Parliament; Anti-Discrimination NSW).
  • South Australia, 2024 (verified). The Conversion Practices Prohibition Act 2024 received assent on 3 October 2024 and commenced on 1 April 2025. It mirrors NSW but requires conduct on "more than 1 occasion", with up to five years for serious harm (SA Legislation).
  • Tasmania, Western Australia, Northern Territory. No law as of October 2026. A Greens private member's bill in Tasmania was tabled in September 2026; Western Australia's Attorney-General has promised legislation "before the end of 2026" (OUTinPerth, LGBT press, not confirmed).

Enforcement and complaints. In its February 2026 statutory review paper, the Victorian Law Reform Commission (VLRC) said "To date, there have been no criminal prosecutions under the Act", and that it was "not aware of any prosecutions under any of those laws" in other Australian jurisdictions. The Victorian Equal Opportunity and Human Rights Commission had received 14 reports in four years (VLRC 2026). The same paper cites a 2025 family court case, Re Devin, in which experts said "a lack of clarity about how the Act applies to health professionals may discourage them from treating children with gender issues"; the judge said this "may explain some of the difficulties" in obtaining expert evidence. During drafting, a Royal Australian and New Zealand College of Psychiatrists (RANZCP) representative said "The wording is just too vague" (SBS 2021).

New Zealand

The Conversion Practices Prohibition Legislation Act 2022 received assent on 18 February 2022. It covers sexual orientation, gender identity and gender expression. Section 5(1) defines a conversion practice as "any practice, sustained effort, or treatment" done "with the intention of changing or suppressing" any of them. Section 5(2) excludes:

(a) any action that a health practitioner takes when providing a health service if the health practitioner— (i) considers in their reasonable professional judgement it is appropriate to take that action; and (ii) complies with all legal, professional, and ethical standards when taking the action; or (b) assisting an individual who is undergoing, or considering undergoing, a gender transition; or (c) assisting an individual to express their gender identity; or (d) providing acceptance, support, or understanding of an individual; or (e) facilitating an individual's coping skills, development, or identity exploration... — (Conversion Practices Prohibition Legislation Act 2022, s. 5(2))

Performing a conversion practice on someone under 18, or who lacks decision-making capacity, carries up to three years' imprisonment (s. 8). Doing so to anyone and causing "serious harm" carries up to five years (s. 9). Consent is no defence, and prosecutions need the Attorney-General's consent. The Act also made conversion practices unlawful under the Human Rights Act, so people can complain to the Human Rights Commission. In May 2023 the Spinoff reported no police complaints, no requests for the Attorney-General's consent, and 33 inquiries to the commission, none escalated (The Spinoff 2023). Up-to-date figures for 2026 were not found.

Europe

As of October 2026, eight European Union (EU) member states have national bans, according to the European Commission: Belgium, Germany, Greece, Spain, France, Cyprus, Malta and Portugal (European Commission C(2026) 3333). Norway and Iceland, outside the EU, also have bans, and the Netherlands has passed one that is not yet in force. Translations below are ours.

  • Malta (2016, amended 2023). The Affirmation of Sexual Orientation, Gender Identity and Gender Expression Act (Cap. 567) was the first national ban in Europe. Article 2 defines conversion practices as efforts that aim "to change, repress and, or eliminate" orientation, gender identity or expression, but excludes "any services and, or interventions related to the exploration and, or free development of a person and, or affirmation of one's identity ... through counselling, psychotherapeutic services", and "any healthcare service related to the treatment of a mental disorder". Professionals may not perform these practices on anyone, of any age. Anyone may be prosecuted for practising on a "vulnerable person", including under-16s. Professionals face fines of €2,000–10,000 and/or up to a year in prison (Cap. 567).
  • Germany (2020). The Act to Protect against Conversion Treatments (KonvBehSchG) bans "treatments aimed at changing or suppressing sexual orientation or self-perceived gender identity" on under-18s, and on adults whose consent was flawed (§§1-2). Section 1(3) says hormones or surgery expressing a person's "self-perceived gender identity" are not conversion treatment. The explanatory memorandum says psychotherapeutic conversations about a person's life situation "are generally not conversion treatments" (KonvBehSchG; BT-Drs. 19/17278). The penalty is up to one year. Parents are exempt unless they "grossly breach" their duty of care. A 2021 promise to extend the law to adults was never enacted.
  • France (2022). Law no. 2022-92 created article 225-4-13 of the Penal Code: "repeated practices, behaviour or statements" aiming to change or repress orientation or gender identity and harming physical or mental health. Penalties are 2 years and €30,000, or 3 years and €45,000 where the victim is a minor. France is unusual in writing an exploratory-caution clause into the offence. No offence is committed when repeated statements "merely urge caution and reflection, having regard in particular to their young age" on someone questioning their gender identity and considering medical transition (Loi n° 2022-92, as reported; Légifrance could not be accessed directly). A matching clause covers health professionals (Public Health Code art. L.4163-11).
  • Spain (2023). Article 17 of Law 4/2023 (the "trans law") bans "aversion, conversion or counter-conditioning methods, programmes and therapies, in any form", "even with the consent of the person concerned". This is an administrative offence with fines of €10,001–150,000, and it has no therapy carve-out (BOE-A-2023-5366). A bill to make it a crime passed the Congress of Deputies on 25 June 2026; its Senate outcome is not confirmed. Madrid's 2023 regional law moved the other way, stating that psychological counselling or psychiatric evaluation is not discrimination. Its constitutional challenge is unresolved (not confirmed).
  • Portugal (2024). Law 15/2024 created Penal Code article 176-C. It punishes subjecting another person to acts aiming to change or repress orientation, gender identity or expression, expressly including "psychotherapeutic" ones, with up to 3 years, or 5 if irreversible bodily changes result. Procedures under the gender self-determination law are exempt (Diário da República). On 2 April 2025 Portugal's Ombudsman asked the Constitutional Court to strike the article down for vagueness (Provedor de Justiça); no ruling was found.
  • Belgium (2023). The law of 31 July 2023 criminalises physical intervention or "psychological pressure" intended to repress or change orientation, gender identity or expression (1 month–2 years). It excludes "help and assistance offered in the context of mental and physical healthcare relating to the exploration and development" of orientation or gender identity, and transition care by health professionals (Loi du 31 juillet 2023).
  • Greece (2022). Article 62 of Law 4931/2022 bans "any treatment aiming to change or suppress" orientation, gender identity or expression on minors and adults under guardianship. Adults may receive it with "explicit consent", and there is no exploratory carve-out (Law 4931/2022).
  • Cyprus (2023). Criminal Code article 233B, titled "sham conversion therapies", punishes practices aiming at "change, suppression or elimination" (up to 2 years; 3 for minors). It exempts counselling, psychological or medical services "concerning exploration and/or free development", provided they do not seek change or suppression (Law 39(I)/2023).
  • Iceland (2023). Penal Code article 227b punishes making a person undergo "non-evidence-based treatment" to suppress or change orientation, gender identity or expression "by coercion, deception or threats" (up to 2 years; 4 for children) (University of Iceland law mirror).
  • Norway (2024). Penal Code sections 270-270b, in force from 1 January 2024, punish whoever "violates" another person by "psychotherapeutic, medical, alternative-medicine or religiously based methods" intended to make them "change, deny or suppress" their orientation or gender identity (up to 3 years; 6 if aggravated). For under-18s the "violation" element is dropped. There is no statutory carve-out. Parliament's committee report records the ministry's view that parents talking with a child, or refusing consent to gender-affirming treatment, are not covered (Lovdata). Local news reports no prosecutions in the first two years.
  • Netherlands (2026, not yet in force). The Act criminalising conversion acts (Stb. 2026, 294), published on 30 September 2026, adds article 285ba to the Penal Code. It covers professionals and organisations acting on minors (up to 1 year), and adults where dominance is abused. Its carve-out is the strongest in Europe for exploratory work: the offence does not include "the aim of urging restraint, caution or reflection with regard to a social or medical transition", and a doctor or carer acting within professional standards "is not punishable" (Staatsblad 2026, 294).

No law yet. Ireland lists a Prohibition of Conversion Practices Bill as "Heads in preparation" (Government Legislation Programme, Autumn 2026). Denmark plans a bill for under-18s in February 2027 (Danish Ministry of Justice). Finland's parliament approved a citizens' initiative in March 2025, but the government said no bill would follow this term. Austria has no draft. Switzerland's Federal Council said in September 2026 that current law "already offers comprehensive protection", though a uniform federal rule "could make sense"; several cantons (Neuchâtel, Valais, Fribourg, Vaud) have their own bans (Swiss Federal Department of Home Affairs).

EU level. A European Citizens' Initiative to ban conversion practices across the EU collected 1,128,063 verified signatures. On 13 May 2026 the Commission declined to propose legislation. It instead committed to a non-binding recommendation in 2027 and a study considering "the level of coercion and pressure involved" (C(2026) 3333).

Latin America

  • Brazil (1999, 2018). Brazil was the first country to act, through its psychology regulator rather than a law. Federal Council of Psychology (CFP) Resolution 001/1999, art. 3, forbids psychologists to favour "the pathologisation of homoerotic behaviour or practices" or to steer gay people towards "unsolicited treatments". Resolution 01/2018, art. 8, extends this to trans people. It forbids psychologists to propose or take part, "from a pathologising perspective", in services aimed at "conversion, reversion, readjustment or reorientation therapies" of gender identity (CFP resolutions, via CRP-MG). Neither resolution has an exploratory carve-out. A 2017 federal court order allowing "reorientation" care was suspended by the Supreme Federal Court in April 2019 (Rcl 31818, as reported).
  • Mexico (2024). A decree published on 7 June 2024 added article 209 Quintus to the Federal Penal Code. It sets 2-6 years' prison for anyone who performs, imposes or finances "any type of treatment, therapy, service or practice that obstructs, restricts, impedes, impairs, nullifies or suppresses" a person's sexual orientation, gender identity or expression. Penalties double for victims under 18. Parents receive only a warning. Health professionals can also be suspended for 1-3 years (General Health Law art. 465 Ter) (Diario Oficial, 7 June 2024). It applies to all ages and has no exploratory or neutral-therapy carve-out. The word "obstructs" is broad: on its face it could reach a clinician who advises delay.
  • Ecuador (2014). The Comprehensive Organic Penal Code (COIP), art. 151, treats intent "to modify gender identity or sexual orientation" as an aggravating factor in torture (10-13 years). It is not a standalone ban on talk therapy (COIP).
  • Argentina (2010), Uruguay (2017), Chile (2021). These mental-health laws are often listed by trackers as "bans", but they are diagnosis rules. Argentina's Law 26.657, art. 3, says no mental-health diagnosis may be based solely on "sexual choice or identity" (Infoleg). Uruguay's Law 19.529, art. 4, and Chile's Law 21.331, art. 7, say the same of orientation and gender identity (IMPO; Diario Oficial de Chile). None creates an offence.
  • No national ban. Colombia's bill passed the lower house in 2024 but was archived in the Senate. A new Costa Rican bill was filed in September 2026. Peru and Bolivia have no ban (not confirmed).

Asia, the Middle East and Africa

  • Taiwan (2018). A Ministry of Health and Welfare interpretive letter of 22 February 2018 said conversion therapy is not a medical act, and that practitioners may be pursued under existing criminal and child-welfare laws (news reports; the letter's text was not reviewed). No statute has been enacted.
  • Israel (2022). A Health Ministry director-general directive of February 2022 bars licensed health professionals from offering conversion therapy, on pain of disciplinary action (Times of Israel). It does not cover religious counsellors, and whether it covers gender identity is not confirmed. A 2020 Knesset bill passed a preliminary reading but was not enacted.
  • India (2021-22). In S. Sushma v. Commissioner of Police (2021), the Madras High Court prohibited attempts to medically "cure" sexual orientation or gender identity. The National Medical Commission told state medical councils in August 2022 that conversion therapy is "professional misconduct" (as reported; text not reviewed).
  • Vietnam (2022). Health Ministry Official Letter 4132/BYT-PC tells providers not to treat homosexuality, bisexuality or being transgender as a disease, and not to force treatment. It allows "only psychological support, performed by people with knowledge of gender identity" (LuatVietnam). It carries no penalties.
  • Elsewhere. We found no ban in South Korea, Japan, Hong Kong, Thailand, the Philippines (national level), other Middle Eastern countries or Africa, including South Africa (absence not confirmed).

The core controversy: do bans chill exploratory therapy?

The asymmetry in the texts

Most laws that cover gender identity share one structure. They protect therapy that helps a person who is "considering" transition, and therapy that offers "identity exploration". None of the texts reviewed here protects, in so many words, helping someone decide not to transition, or helping someone detransition. A therapist who explores whether a teenager's distress is linked to trauma or same-sex attraction is protected only if a court later agrees that this was "exploration" and not an attempt to "change or suppress".

Four drafting choices make this risk larger or smaller:

  • "Suppress" as well as "change". Nearly every law reviewed here targets suppression or repression, not just change; Canada's applies "repress" only to a "non-cisgender gender identity". Critics argue that encouraging someone to wait before transitioning could be framed as suppressing an identity.
  • Intent vs effect. Most laws require a purpose or intention to change or suppress. Mexico's ban on any practice that "obstructs" or "restricts" an identity reads more like an effects test.
  • Professional-judgement exemptions. New Zealand, Queensland, NSW, South Australia, the ACT and Victoria protect practitioners acting within "reasonable professional judgement". Spain, Mexico, Norway and Greece have no such clause.
  • Express caution clauses. Only France, the Netherlands and Queensland expressly protect urging "caution and reflection", "restraint", or "probing" an experience of gender identity.

Arguments that bans chill exploration

The most influential statement came from the Cass Review, the 2024 independent review of NHS gender services for young people led by paediatrician Hilary Cass:

The intent of psychological intervention is not to change the person's perception of who they are but to work with them to explore their concerns and experiences and help alleviate their distress... It is harmful to equate this approach to conversion therapy as it may prevent young people from getting the emotional support they deserve. — (Cass 2024, para. 11.6)

Cass also wrote that "No formal science-based training in psychotherapy, psychology or psychiatry teaches or advocates conversion therapy" (para. 11.7). She urged that "strong safeguards must be built into any potential legislation on conversion practices" (para. 17.22). The review said terms such as "affirmative" and "exploratory" had been "weaponised" (para. 11.4).

Other evidence of a chilling effect:

  • Australian courts and psychiatrists. In Re Devin (2025), experts told an Australian family court that unclear wording in Victoria's Act "may discourage" health professionals from treating children with gender issues (VLRC 2026). A RANZCP spokesperson called the draft "just too vague" (SBS 2021).
  • Therapists' own reports. An international survey of exploratory therapists in the Journal of Sex & Marital Therapy described their "anxiety in working in a hostile professional environment" and strategies "to minimize risk of allegations of conversion therapy" (Jenkins & Panozzo 2024). It is a self-selected sample of therapists who already practise this way.
  • The US government review. The HHS review said "characterizing as 'conversion therapy' any approach focused on reducing a minor's distress about their body or social role is a problematic and potentially harmful rhetorical device" (HHS 2025).
  • Therapy First (formerly the Gender Exploratory Therapy Association, an advocacy group of exploratory clinicians) supports US bans as written, but says "misinterpretation and misuse of these laws has led to a chilling effect that has limited the care available to this population" (Therapy First FAQ, advocacy).
  • Clinicians writing in Canada. A 2024 paper in the journal of the Canadian Academy of Child and Adolescent Psychiatry argued that "psychodynamic psychotherapy for gender dysphoria is not conversion therapy" (Sinai & Sim 2024).

Arguments that bans do not chill legitimate therapy

  • The texts protect exploration. Supporters point out that nearly every law cited here exempts "identity exploration" or professional judgement. Therapy First itself says US laws, "when read contextually and accurately", support its approach.
  • Exploration can be a cover. Legal scholar Florence Ashley argues that gender-exploratory therapy shows "strong conceptual and narrative similarities" with older conversion practices and may be unethical (Ashley 2023). This is an argument essay with no data. Critics also note that some religious counsellors now describe their work as "exploratory".
  • Professional bodies. Many professional associations support bans that include gender identity. The UK Royal College of Psychiatrists backed the 2026 draft bill because it supports "appropriate exploratory conversations" (GOV.UK). UKCP still opposes conversion therapy "for any age" despite leaving the MoU.
  • No prosecutions. If therapists were being prosecuted for asking questions, it would show. Instead, enforcement is almost nil.

What actually happens: prosecutions and complaints

Across every jurisdiction checked, criminal enforcement is close to zero:

  • Victoria: "no criminal prosecutions" since 2022; 14 civil reports to the equality commission in four years (VLRC 2026).
  • Other Australian states: the VLRC knew of no prosecutions.
  • New Zealand: no police complaints in the first year; 33 inquiries to the Human Rights Commission, none escalated (The Spinoff 2023).
  • Canada: no charges known to the Justice department as of January 2023 (Global News).
  • Norway, Spain, France: no prosecutions or sanctions reported (news reports; not confirmed).
  • United States: the best-known enforcement was a consumer-fraud case against a religious sexual-orientation group (Ferguson v. JONAH, 2015), not a gender case.

This cuts both ways. Supporters say the laws work by deterrence. Critics say that a law almost never enforced yet widely feared shapes practice mainly through professional caution: clinicians, employers and insurers avoid anything that might attract a complaint. Neither side has published data measuring how often therapists decline gender-questioning clients because of these laws.

Chiles v. Salazar and its implications

Chiles is the first ruling by a national top court that a conversion therapy ban, as applied, violates free speech. Its reasoning rests on the same asymmetry described above. Colorado allowed counsellors to support a young person "undergoing gender transition" but forbade talk therapy aimed at the opposite outcome. That, the majority held, is regulation by viewpoint.

The practical effects as of October 2026:

  • Talk therapy in the US. Bans on licensed counsellors' talk therapy with consenting minors now face strict scrutiny. A Colorado injunction and a Michigan judgment followed within months (both as reported). Bans on physical or aversive interventions are not affected.
  • Rewriting the laws. States may try viewpoint-neutral rules, which Justice Kagan suggested would raise "a different and more difficult question". Colorado's 2026 rewrite around a "predetermined outcome" is one such attempt.
  • For questioning young people. The ruling protects counsellors who explore or question a gender identity, and also counsellors whose goal is to change one. It does not decide which therapy is effective.

For more on US developments, see the United States.

What this means for detransitioners and questioning people

  • No law reviewed here bans helping someone detransition. Supporting a person who no longer identifies as trans is not an attempt to change their identity. Several laws protect "identity exploration and development" in any direction.
  • Exploration is generally legal, but practice varies. In most places with bans, an exploratory therapist acting within professional standards is not committing an offence. The barrier is more often professional culture, fear of complaints, or clinic policy. The support directory lists therapists who work exploratorily.
  • Ask the question directly. A prospective therapist can be asked whether they explore causes of distress or affirm first. The answer will show their approach better than the law will. See gender exploratory therapy.
  • Detransitioners report gaps in care. In a survey of 957 people in the US and Canada who had detransitioned, many felt providers had no idea how to help them (Rackliff et al. 2025). That gap appears to come more from missing services than from any law. See healthcare during detransition.
  • Coercion against detransitioners. Most laws are written in a direction-neutral way ("change or suppress" an identity), but their carve-outs only name transition. Whether pressuring a detransitioner to resume transition would count as a conversion practice has not been tested.

Detransitioner accounts

On /r/detrans, a recurring theme is the belief that conversion therapy laws stopped therapists from asking questions. Some of these comments describe the laws more broadly than their text, but they show how the laws are understood by the people they affect:

Believe it or not, they aren't really legally allowed to in many states. Many of those laws that are passed to "Stop conversion therapy" have these sort of provisions built into it. Professionals can't question you or recommend different types of therapy to resolve the problem as it's considered "conversion therapy". —duffmanhb, detransitioner

I'm from Canada and here it's become illegal to not affirm a persons gender identity in therapy through their "anti conversion" law they set in place. —William_Shakespear_, desisted female

The Canadian text does not in fact require affirmation (see Canada); the comment records a perception. Others describe the effect on clinicians rather than on the law itself:

Basically he told me he is pressured to not question teens about their choice to transition cuz that would be labelled as transphobic by his peers. —AbsolRiatun, medically desisted

A psychologist's patient described her clinician working around the rules:

I have a normal psychologist who has to deal with this, there are cases when it's obvious the person just went through social contagion or is transitioning to scape from abuse/trauma but she isn't allowed to say so, so she walks on eggshells and tries her best to guide the patients and slow down the rushed process. —LostSoul1911, detrans female

"Transition as conversion therapy"

Many commenters turn the label around. They argue that steering gender-nonconforming gay and lesbian young people into transition is itself a kind of conversion, because it makes them heterosexual in appearance:

I'm pretty thoroughly convinced that the only "trans conversion therapy" happening is the socially-enforced transitioning of GNC gay people (usually kids and teens) to make them better conform to gender stereotypes and expectations. Regressive af. —UtsuroBuneWoman, desisted female

One commenter who went through religious conversion therapy said her therapist switched approach when it failed:

Considering my gay conversion "therapist" switched to gender affirmation on failing to abuse me into being straight, I can definitely see the overlaps... —DetransIS, detrans female

("GNC" means gender-nonconforming.) For the link between same-sex attraction and transition, see internalised homophobia.

Trans perspectives

Trans commenters who were put through conversion attempts describe them as abuse, and many see bans as basic protection:

Conversion torture was only just that. Torture, trauma and abuse. Gaslighting and attempted brainwashing. Its left me with multiple phobias and lots of trauma... —ZeltronJedi, trans woman (MTF)

Not every trans commenter equates therapy with conversion. Some draw the same line that exploratory therapists draw:

Then when you suggest therapy because it's helped you and other trans people you know to live more at peace with who you are, they will accuse you of supporting conversion therapy. —GrilledCassadilla, trans woman (MTF)

…it's not conversion therapy to help someone detransition, or delay transition, necessarily, if they're following their patients lead and affirming their agency in the situation - "conversion" is about setting up the norm as the most desirable goal, which is not what therapy is for. —JudiesGarland, trans man (FTM)

The two groups agree more than the debate suggests. Both reject coercive attempts to force an identity on someone. They disagree about whether questioning a gender identity in therapy is, in itself, an attempt to force one.

Limitations

  • Statuses are as of October 2026, and several matters are unresolved. These include the England and Wales draft bill, Spain's criminal bill, Portugal's constitutional challenge, the Chiles remand, Michigan's judgment and the Dutch commencement date.
  • Some texts could not be read directly. France's Légifrance and Brazil's CFP site blocked access; their wording comes from official reproductions. Taiwan's, Israel's and India's measures are described from news reports.
  • Translations of non-English statutes are ours and are not official.
  • US state counts come from the Movement Advancement Project, an advocacy group. Our own review covered Colorado only.
  • Absence of reported prosecutions is not proof that none occurred; few governments publish these figures.
  • Reddit accounts are self-selected. They show how the laws are perceived, not how often therapists actually refuse to explore.
References
  • American Psychological Association (2009). Report of the APA Task Force on Appropriate Therapeutic Responses to Sexual Orientation. PDF.
  • UN Independent Expert on sexual orientation and gender identity (2020). Practices of so-called "conversion therapy", A/HRC/44/53. UN Digital Library.
  • Cass (2024). Independent review of gender identity services for children and young people: Final report. study page, source.
  • US Department of Health and Human Services (2025). Treatment for Pediatric Gender Dysphoria: Review of Evidence and Best Practices. study page, source.
  • Ashley (2023). Interrogating Gender-Exploratory Therapy. Perspectives on Psychological Science. study page, source.
  • Rackliff et al. (2025). "Providers had no idea what to do with me". International Journal of Transgender Health. study page, source.
  • Singh, Bradley & Zucker (2021). A Follow-Up Study of Boys With Gender Identity Disorder. Frontiers in Psychiatry. study page, source.
  • Wright, Rochussen & Stagg (2026). Flawed methods and overstated conclusions regarding 'Brain Sex': a peer review of Kurth et al. (2022). Theory and Society. study page, source.
  • Clarke & Spiliadis (2019). 'Taking the lid off the box': The value of extended clinical assessment for adolescents presenting with gender identity difficulties. study page, source.
  • Jenkins & Panozzo (2024). "Ethical Care in Secret": Qualitative Data from an International Survey of Exploratory Therapists Working with Gender-Questioning Clients. Journal of Sex & Marital Therapy. source.
  • Sinai & Sim (2024). Psychodynamic psychotherapy for gender dysphoria is not conversion therapy. J Can Acad Child Adolesc Psychiatry. source.
  • Therapy First (advocacy). FAQ. source.
  • Canada: Criminal Code ss. 320.101-320.104, source; Library of Congress (2022), source; Global News (2023), source; Ontario Bill 77, source; Nova Scotia S.N.S. 2018 c. 28, source; Quebec S.Q. 2020 c. 28, source.
  • United States: Chiles v. Salazar, No. 24-539 (2026), opinion; Movement Advancement Project (advocacy), source; Ferguson v. JONAH, source.
  • United Kingdom: Draft Conversion Practices Bill (CP 1604), source, explanatory notes, press release; consultation analysis, source; written statement 17 Jan 2023, source; Commons debate 9 Sept 2026, source; Scottish Government letter 4 Sept 2026, source; NI Assembly bill page, source; MoU (July 2024), source; UKCP withdrawal (2024), source; UKCP guidance (2023), source.
  • Australia: ACT A2020-49, source; Queensland Public Health Act 2005, source; Victoria Act 3/2021, source; NSW Conversion Practices Ban Act 2024, source, Anti-Discrimination NSW; South Australia Act 2024 No 39, source; Victorian Law Reform Commission consultation paper (2026), source; SBS (2021), source.
  • New Zealand: Conversion Practices Prohibition Legislation Act 2022, source; The Spinoff (2023), source.
  • Europe: Malta Cap. 567, source; Germany KonvBehSchG, source, BT-Drs. 19/17278, source; Spain Ley 4/2023, source; Portugal Lei 15/2024, source; Belgium law of 31 July 2023, source; Greece Law 4931/2022, source; Cyprus Law 39(I)/2023, source; Iceland Penal Code art. 227b, source; Norway Penal Code ss. 270-270b, source; Netherlands Stb. 2026, 294, source; Ireland legislation programme (2026), source; Denmark legislative programme 2026/27, source; Switzerland Federal Department of Home Affairs (2026), source; European Commission C(2026) 3333, source; Provedor de Justiça (Portugal), source.
  • Latin America, Asia: Brazil CFP resolutions 001/1999 and 01/2018, source; Mexico DOF 7 June 2024, source; Ecuador COIP, source; Argentina Ley 26.657, source; Uruguay Ley 19.529, source; Chile Ley 21.331, source; Israel, Times of Israel (2022), source; Vietnam Official Letter 4132/BYT-PC, source.

Last updated: · 14 views

Suggest an Article or an Improvement

Spotted something missing, unclear or wrong on this page, or have an idea for a related article? Let us know and we'll take a look.

Only if you'd like a reply

Related pages: