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

Risk Category Likelihood Impact Mitigation Owner

(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