When to use this
Use this template whenever a decision could affect people who share the protected characteristic of sex, gender reassignment, or both — for example a facilities policy, a service-eligibility rule, a single-sex or separate-sex provision, or a change to how you collect gender information. An Equality Impact Assessment (EqIA) is the artefact that shows you had due regard to the protected characteristics the public sector equality duty (section 149) requires, and that your decision is proportionate, case by case, on the facts.
How to use this template
Work through the sections in order. Do not treat it as a tick-box exercise: the value is in the reasoning you record, not in the boxes you fill. Start from the presumption of inclusion; treat any restriction as a justified exception, not an entitlement. Consider each protected characteristic on its own terms — sex and gender reassignment are two separate characteristics and must be assessed separately, not collapsed together. For the wider framing, see /resources/the-eqia-every-trans-inclusion-policy-needs/ and /resources/what-defensible-decision-making-means/.
Decision being assessed
Decision title: Date of assessment: Owner / accountable lead: Others consulted:
Background facts
What is the decision, policy, or practice? Who is affected? What factual problem prompted it? (Record the evidence — not assumptions.)
Protected characteristics engaged
Sex — Who is affected by sex? What is the impact on women and on men, considered separately? Has the meaning of “sex” been correctly understood? (Following For Women Scotland Ltd v The Scottish Ministers [2025] UKSC 16, “sex” in the Equality Act 2010 means biological sex, not sex as modified by a Gender Recognition Certificate. This does not require exclusion of anyone and does not affect gender reassignment as a separate characteristic.)
Gender reassignment — Who is affected by gender reassignment? What is the impact on trans people, considered separately? What is the impact on people who are proposing to undergo, are undergoing, or have undergone a process (or part of one) to reassign their sex?
Other characteristics — Note any other protected characteristic engaged (age, disability, pregnancy and maternity, race, religion or belief, sexual orientation).
Evidence and consultation
Evidence relied on: Consultation undertaken: (with whom, when, and what they said) Gaps in evidence: (and whether the decision can safely proceed despite them)
Options considered
Record at least three options, including a “do nothing” option and a mixed or inclusive option.
Option A — Do nothing / retain the status quo: Option B — [Describe]: Option C — Inclusive or mixed option: (the option that restricts the fewest people)
Proportionality assessment per option
For each option, answer each question. Restriction must be a proportionate means of achieving a legitimate aim, applied case by case.
Option [A/B/C]
Legitimate aim: (What is the aim? Is it legitimate?) Rational connection: (Will this option achieve it?) Least restrictive: (Is there a less restrictive option that would also achieve it?) Balance: (Weigh the needs of those who would benefit against the impact on those restricted — including trans people. Is the balance fair?)
Impact on each group
Impact on women (by sex): Impact on men (by sex): Impact on trans people (by gender reassignment): Impact on others: (any other group identified above) Differential impact: (where effects fall unevenly, record why)
Mitigations
Mitigation: Owner: Residual impact after mitigation:
Decision and rationale
Decision taken: Rationale: (Why this option, in your own words. Reference the legitimate aim, the proportionality test, and the balance of needs.) Restriction is a last resort: (Confirm you considered inclusive options first and explain why they did not suffice.)
Review
Review date: Review owner: Trigger for earlier review: (e.g. a change in law, guidance, or circumstances)
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.