Guide · 15 July 2026

Board or trustee decision paper

A template decision paper for contested trans-inclusion decisions at board level — frames the question, the legal context, options, risks, and the proportionality rationale trustees need to see and approve.

By Joanne Lockwood · 3 min read

When to use this

Use this template when a trans-inclusion decision is significant enough to need board or trustee approval — for example a change to a single-sex or separate-sex service, a facilities policy, or a policy that could be challenged. The board’s job is to authorise a defensible, documented process, not to reach a particular outcome. Named accountability matters: a paper that names the sponsor, the decision-maker, and the reviewer is a governance position.

How to use this template

Complete each section. Be candid about risk — a paper that understates risk invites challenge. The proportionality justification is the heart of the paper; trustees should test it, not rubber-stamp it.

Title

Paper title: Date: Sponsor / owner: Recommendation: (one line — what are you asking the board to approve?)

Background

What is the issue? How did it arise? What is the current position?

The decision required

What decision is the board being asked to make? What happens if the board defers?

Equality Act 2010: (Which protected characteristics are engaged — sex and gender reassignment, considered separately? Which Schedule 3 exceptions, if any, are in play? Note that exceptions are permissive powers, not duties to exclude.) Case law: (For Women Scotland Ltd v The Scottish Ministers [2025] UKSC 16 held that “sex” in the Equality Act means biological sex. It did not require exclusion of anyone and did not affect gender reassignment as a separate characteristic under section 7.) EHRC statutory Code of Practice on Services, Public Functions and Associations: (The Code comes into force on 5 August 2026, with the 2011 Code revoked the same day. It is guidance an organisation must have regard to — not law itself. Record that the board has had regard to it.) Public sector equality duty (s149): (Due regard to sex and to gender reassignment, separately.)

Options analysis

For each option, record the pros, cons, and risk. Include at least a “do nothing” option and an inclusive or mixed option.

Option A — Do nothing:

  • Pros:
  • Cons:
  • Risk:

Option B — [Describe]:

  • Pros:
  • Cons:
  • Risk:

Option C — Inclusive or mixed option:

  • Pros:
  • Cons:
  • Risk:

Proportionality justification

Legitimate aim: Is the means rationally connected to the aim? Is it the least restrictive means? Is the balance of needs fair — including the needs of trans people?

Equality impact

Impact on women (by sex): Impact on trans people (by gender reassignment): EqIA reference:

Risks and mitigations

RiskCategoryLikelihoodImpactMitigationOwner

(Categories: legal, reputational, operational, data-protection.)

Financial and resource implications

Costs: Resourcing:

Stakeholder and consultation position

Who was consulted? What did they say? How has that informed the recommendation?

Decision and rationale

Decision: Rationale: (In the board’s own words — why this option, why it is proportionate, why restriction is a last resort.)

Review mechanism

Review date: Review owner: Trigger for earlier review:

Sign-off: (Sponsor, board chair, date.)


This template provides general information and does not constitute legal advice. It is a scaffold to support your own documented, proportionate decision-making. Adapt it to your context and take specialist advice where your decision warrants it.

Take this further

  • Policy Foundations

    Gives trustees the seven-area gap analysis behind the recommendation, so the paper lands on evidence rather than assertion.

  • Proportionality Check

    Lets the board run the proposed decision through a structured four-limb test and see the risk level before they authorise it.

  • Board facilitation

    For a contested decision, a facilitated board session tests the reasoning with the people who have to own it.

Sources