50.7%

of organisations have no formal policy on trans and nonbinary inclusion.

This is the single most arresting finding of the survey. Over half of respondents — people who chose to engage with research on this topic — report that their organisation has no dedicated policy. For the broader population of UK employers, the figure is almost certainly higher.

Among those that do have a policy, coverage is uneven. 49.3% of organisations with a policy cover both trans and nonbinary identities. But 22.4% address only binary trans identities, and 28.4% of respondents either weren’t sure what their policy covered or said it didn’t explicitly address gender identity at all.

Policy as a living document

A policy that exists but hasn’t been reviewed is a policy that may no longer reflect the law, the evidence, or the reality of your workforce. The survey found:

• 29.9% of organisations review their inclusion policies annually
• 22.4% review every 2–3 years
• 26.9% had no set review schedule at all
• 20.9% didn’t know when their policy was last reviewed

Almost half of organisations either have no review cycle or don’t know whether one exists. This means policies may be outdated, inconsistent with current case law, or disconnected from the organisational practices they’re supposed to govern.

Policy scope and integration

Where policies do exist, they vary significantly in scope. Some are standalone trans inclusion policies; others are embedded within broader EDI or HR frameworks. The survey didn’t assess quality — only existence, coverage, and review cadence. But what’s clear is that “having a policy” means very different things across different organisations.

6.1%

of organisations tie trans and nonbinary inclusion outcomes to executive performance indicators.

Leadership matters — not as a symbolic gesture, but as a structural signal. When senior leaders visibly own inclusion, it authorises managers to act, gives HR credibility to implement, and tells employees that the organisation’s commitment is not discretionary.

The survey reveals a significant accountability vacuum:

• 6.1% link inclusion outcomes to executive KPIs — the strongest form of accountability
• 17.2% have board or senior leadership engagement on trans inclusion specifically
• 29.1% have a named individual responsible for trans and nonbinary inclusion policy
• 53.7% of respondents said no one at senior level has specific responsibility for this area

The accountability gap

There is a stark disconnect between organisational rhetoric and governance reality. Many organisations reference inclusion in their values, strategies, or annual reports. But when you ask who is personally accountable for translating those commitments into policy, infrastructure, and measurable outcomes, over half say: nobody.

This isn’t a resource problem — it’s a governance choice. Organisations that link EDI outcomes to executive performance metrics have made a structural decision to treat inclusion as a leadership responsibility. The 93.9% that don’t have made a different choice, even if it was made by default.

Named responsibility

Having a named lead is less demanding than KPI accountability, but it still matters. A named individual creates a point of escalation, a contact for policy queries, and a visible signal that someone is paying attention. When 70.9% of organisations have no named lead, the practical effect is that trans and nonbinary inclusion belongs to no one — and therefore to everyone, which in practice means no one.

46.3%

of organisations provide gender-neutral toilet facilities at all or most sites.

Facilities are where policy meets the physical environment. You can write the most progressive inclusion policy in the sector, but if a trans employee can’t use the toilet without anxiety, confrontation, or having to travel to a different floor, the policy is failing in the most basic way.

The survey examined toilet provision, changing facilities, and multi-site consistency:

Toilet provision

• 46.3% provide gender-neutral toilets at all or most sites
• 19.4% provide them at some sites only
• 13.4% have no gender-neutral provision at all
• 20.9% didn’t know what their organisation provides

Changing facilities

Changing rooms and shower facilities are more complex — they involve undressing, which amplifies vulnerability. The survey found that provision is significantly less developed than toilet facilities, with most organisations either not addressing changing rooms at all or leaving arrangements to local discretion.

Multi-site consistency

For organisations with more than one location, consistency is critical. A trans employee who can use an appropriate toilet at head office but not at a regional site experiences the policy as unreliable. The data suggests significant variation across sites, with 19.4% providing facilities at some but not all locations — creating a postcode lottery of inclusion.

36.4%

of organisations that have trans inclusion policies provide no manager guidance on implementation.

Policy without capability is decoration. If managers don’t know what to do when an employee discloses a trans or nonbinary identity, when a name change is requested, or when a colleague raises concerns — the policy exists in name only.

The survey reveals a significant capability gap:

Training provision

• 26.5% of organisations provide training that specifically covers trans and nonbinary inclusion
• 33.8% include it within broader EDI or diversity training
• 25.0% provide no training on this topic at all
• 14.7% didn’t know whether training existed

Manager confidence

Training availability is only half the picture. The critical question is whether managers feel confident to act. The survey asked whether managers have the tools, guidance, and support to handle trans and nonbinary inclusion situations effectively:

• 13.2% said their managers feel well-equipped and confident
• 30.9% said managers have some awareness but lack practical guidance
• 22.8% said managers are not equipped at all
• 33.1% didn’t know how confident their managers were

When one-third of respondents can’t assess their managers’ capability, that is itself a governance finding. It means manager readiness isn’t being measured, monitored, or supported in any structured way.

Scenario-based support

The most practical form of manager support is scenario-based guidance — clear, specific instructions for common situations like name changes, pronoun updates, medical leave, and workplace challenges. This is where the 36.4% gap bites hardest: organisations that created a policy but gave managers nothing to work with when they need to apply it.

41.0%

of organisations have no formal process for employees to update their name or gender marker in HR systems.

HR systems, payroll, directories, email, and IT infrastructure are the administrative backbone of identity at work. When these systems can’t accommodate a name change, don’t allow non-binary gender markers, or require an employee to out themselves to IT support — the organisation is creating friction where there should be none.

Name and gender marker changes

• 27.2% have a formal, documented process for updating name and gender markers
• 20.6% handle it informally — on a case-by-case basis
• 41.0% have no process at all
• 11.0% didn’t know whether a process existed

Pronoun recording

Whether systems allow employees to record and display their pronouns is a practical indicator of inclusion infrastructure:

• 22.1% of organisations have systems that allow pronoun recording
• 47.8% do not
• 30.1% didn’t know

Administrative friction

These aren’t abstract issues. For a trans or nonbinary employee, a name change that requires emailing HR, waiting for IT, chasing payroll, and manually correcting every system individually is not a process — it’s an ordeal. The experience of “coming out” administratively can be as stressful as the personal disclosure, particularly in organisations where the process is ad hoc and depends on the goodwill of individual administrators.

Absence and medical leave

The survey also explored whether organisations have specific provisions for gender-related medical absence — covering transition-related appointments, surgical recovery, or mental health support. The majority of organisations have no specific provisions, relying instead on general sickness absence policies which may not be appropriate for the circumstances.

30.6%

of respondents estimate that 0–10% of trans and nonbinary staff in their organisation would feel comfortable disclosing their identity at work.

Everything else in this survey — policy, leadership, facilities, training, systems — exists to create the conditions for psychological safety. The ultimate test is whether trans and nonbinary employees feel safe enough to be themselves at work. This theme examines what the data says about trust, disclosure, and the conditions that enable or inhibit it.

Disclosure comfort

Respondents were asked to estimate what percentage of trans and nonbinary staff in their organisation would feel comfortable disclosing their identity:

• 30.6% estimated 0–10% would feel comfortable
• 17.9% estimated 11–30%
• 14.2% estimated 31–50%
• 11.2% estimated over 50%
• 26.1% said they didn’t know

Nearly a third of respondents believe fewer than 1 in 10 trans or nonbinary employees in their organisation would feel safe disclosing. And over a quarter don’t know the answer — which itself suggests that disclosure comfort isn’t being monitored or measured.

Barriers to disclosure

The survey explored what respondents perceived as the main barriers preventing trans and nonbinary employees from being open about their identity at work. The most frequently cited barriers included:

• Fear of negative reactions from colleagues
• Concern about career impact or professional credibility
• Lack of visible organisational commitment to trans inclusion
• Absence of visible trans or nonbinary role models at senior levels
• Uncertainty about how the organisation would respond

Allyship and visible support

The presence of visible allies — colleagues and leaders who actively signal support — is one of the strongest predictors of psychological safety. The survey found that most organisations have no structured approach to allyship: no ally networks, no visible signalling, and no expectation that non-trans colleagues actively contribute to an inclusive environment.

23.1%

of respondents reported that their organisation has experienced external pressure to reduce or withdraw trans inclusion commitments.

This final theme examines what may be the most consequential dynamic in the current landscape: whether organisations are maintaining, strengthening, or retreating from their trans and nonbinary inclusion commitments in the face of political, media, and social pressure.

External pressure

Nearly a quarter of respondents said their organisation has faced external pressure to scale back trans inclusion efforts. This pressure comes from multiple sources:

• Media coverage and public commentary
• Political rhetoric and legislative uncertainty
• Organised campaigning targeting employers
• Customer or client concerns
• Internal pushback amplified by external narratives

Regression signals

The survey asked whether organisations had reduced or withdrawn any trans inclusion commitments in the past 12 months. While most reported no change, a notable minority described signals of regression:

• Removing or softening language from public statements
• Pausing planned policy updates or training programmes
• Deprioritising trans-specific initiatives within broader EDI strategies
• Adopting a “wait and see” posture on emerging legal developments

Defensive postures

Perhaps more significant than outright regression is what the report terms “defensive compliance” — organisations that maintain their stated commitments but stop actively investing in the infrastructure that makes those commitments real. This pattern is explored in detail in the Governance Insights.

The effect is a slow erosion of practical inclusion. The policy stays on the website, but the training budget is cut, the facilities audit is postponed, and the manager guidance is quietly shelved. From the outside, nothing has changed. From the inside, everything has.

The resilience question

Not all organisations are retreating. Some respondents described organisations that had explicitly recommitted to trans inclusion in response to external pressure — viewing it as a test of governance resilience rather than a reason to retreat. These organisations tend to have the structural features highlighted elsewhere in this data: named accountability, executive KPIs, clear escalation routes, and visible leadership.