The publication of the Draft Conversion Practices Bill has generated predictable responses. Supporters argue that it is necessary to protect vulnerable people from abusive practices. Opponents argue that it threatens freedom of religion, freedom of speech and the ability of individuals to seek voluntary support consistent with their own values and beliefs. These are important questions. But they are not the only questions.
There is another question that remains whatever happens to the Bill. If the Bill is defeated, what framework governs lawful, voluntary support? If the Bill is amended, what framework governs lawful, voluntary support? If the Bill is enacted, what framework governs lawful, voluntary support? That question does not disappear with the fate of this legislation.
A regulatory vacuum
The Draft Bill repeatedly raises issues of abuse, safeguarding, professional responsibility, public protection and accountability. Yet it says remarkably little about the positive framework within which lawful support should be provided.
The debate therefore risks becoming polarised between those who want a ban and those who oppose one, while leaving unanswered the practical question of how ethical, voluntary support should be recognised and governed.
Where We Stand
Core Issues Trust, the IFTCC and X-Out-Loud oppose abusive practices and support appropriate safeguards to protect vulnerable people from coercion, exploitation and serious harm.
We also have serious concerns about legislative intervention that risks restricting lawful, voluntary support sought by individuals who wish to explore or live consistently with their own values, beliefs and goals. At the same time, we believe the public debate has overlooked a further question. Whatever Parliament ultimately decides, lawful, voluntary support requires a clear framework of professional standards, safeguarding, ethical accountability and independent oversight.
That is the question this paper addresses. It is also the question the IFTCC sought to answer through its application to the Professional Standards Authority. Whether the Draft Conversion Practices Bill is defeated, amended or enacted, that question remains.
The Memorandum of Understanding and the Unresolved Question
For many years, the principal point of reference in this field has been the Memorandum of Understanding on Conversion Therapy in the UK. It has undoubtedly influenced professional practice and public policy. However, as Haynes 2025[1] shows it has not resolved the central question of how lawful, voluntary support should be recognised, governed and held accountable.
The Memorandum of Understanding is not a statutory framework, nor is it an independent system of professional regulation. Its membership has changed over time, organisations have joined and withdrawn, and it has never provided a framework that commands confidence across the full range of practitioners and organisations working with individuals who voluntarily seek support consistent with their own values, beliefs and goals.
The publication of the Draft Conversion Practices Bill exposes that unresolved question. The Bill proposes new criminal offences relating to abusive conversion practices, but it does not establish the positive framework within which lawful, voluntary support should be practised, supervised, safeguarded and held accountable.
The IFTCC’s Experience
For more than two years the International Foundation for Therapeutic and Counselling Choice sought to address precisely that question through its application to the Professional Standards Authority.
The proposed register was designed to provide professional standards, safeguarding, supervision, continuing professional development, ethical accountability and independent complaints procedures for practitioners offering lawful, voluntary support.
The PSA declined to accredit that framework. However, the publication of the Draft Conversion Practices Bill demonstrates that the underlying question has not disappeared. Indeed, it has become more pressing.
Beyond Opposition
Many organisations will campaign either for or against the Draft Bill. That is entirely understandable. However, there is a danger that the wider question is overlooked.
Whatever Parliament ultimately decides, there will remain individuals who voluntarily seek support consistent with their own values, beliefs and goals. How should that support be provided? What standards should govern those who offer it? What safeguards should exist? How should accountability be maintained? Those questions deserve answers whether or not this legislation proceeds.
The Next Stage of the Debate
Perhaps the most significant contribution that can now be made is not simply to argue about whether the Draft Bill should pass. It is to ensure that Parliament, regulators, churches, practitioners and the wider public also engage with the question of what lawful, ethical and professionally accountable voluntary support should look like.
Whether the Draft Bill is defeated, amended or enacted, Parliament, regulators, practitioners and the public will still face the same question: what framework should govern lawful, voluntary support? That is not a substitute for the present debate. It is the debate that will remain long after the present one has ended.
Mike Davidson, PhD
IFTCC
CEO Core Issues Trust www.core-issues.org
[1] https://iftccorg-aabc.kxcdn.com/wp-content/uploads/2025/06/MoU-Haynes-Full-Report.pdf